Select Committee on Environmental Audit Written Evidence


Memorandum submitted by UKPIA'S

  The UK Petroleum Industry Association (UKPIA) represents the UK oil refining and marketing interests of nine oil refining companies. Our member companies supply most of the transport fuels and other oil related products used in the UK. As such, we have a major interest in the topic of road transport fuels and the role of biofuels and welcome the opportunity to respond to the Committee's consultation on this important issue.

  Our responses to the Committee's Inquiry are confined to those questions where we have specific knowledge or expertise.

SUMMARY

  UKPIA's views can be summarised as follows:

    —  The oil industry believes that due to their low cost, on-going availability, and ease of use petrol and diesel will remain the dominant road transport fuels globally to 2030 and beyond, a view that is shared by the International Energy Agency and others in their forecasts of future energy use. However, a range of alternative fuels, including first generation biofuels, will have a role to play.

    —  The industry is currently working towards meeting the Government's target of replacing 5% by volume of road fuels by biofuels by 2010-11 under the Renewable Transport Fuels Obligation (RTFO) and the interim targets of 2.5% in 2008-09 and 3.75% in 2009-10. The introduction of biofuels represents the biggest change to road fuels since the introduction of unleaded petrol. Significant investment and time is being committed by the industry at refineries and in the supply/distribution chain to facilitate the introduction of biofuels and avoid any technical difficulties that could affect consumers.

    —  Biofuels production raises a number of issues over sustainability. The oil industry recognised these issues several years ago and has been working in the LowCVP's Fuels Working Group for the last four years to address them, where possible, with sustainability and greenhouse gas reporting. The reporting was intended as the first step towards a mandatory system, preferably EU-wide. The issues of fuel versus food and displacement (the switch of existing sustainable biomass to biofuel production with the current biomass use being met by new unsustainable production elsewhere) were also recognised but felt to be issues for Government. In this respect we supported the use of a realistic buyout price which drove the introduction of biofuels but also acted as a "safety valve" if agricultural prices rose too much.

    —  Sustainability and greenhouse gas reporting are vital to the acceptability of biofuels. The oil industry has pushed the UK Government to lobby for similar criteria to be incorporated into EU legislation to ensure commonality of approach across the EU and to encourage compliance with sustainability reporting standards in producing countries once these are established. Greenhouse gas reporting is particularly important as biofuels can produce differing greenhouse gas savings depending upon the type of feedstock, its source and the conversion processes.

    —  In the UK, the RTFO is seen as a one of several means of reducing CO2 emissions from road transport. However, in most EU countries biofuels are seen as a means of supporting the rural economy. This latter approach is reflected in the targets set by the EU to replace a certain percentage of road fuels with biofuels without any constraint on the greenhouse gas emissions saved.

    —  The oil industry is actively developing and/or deploying new technology which will reduce emissions of greenhouse gases such as second generation biofuels, wind, solar, carbon capture and storage, hydrogen and also fundamental research. Energy efficiency is also being improved in the industry's operations for example by installing gas fired CHP in refineries. This is backed by active participation in groups like the Low Carbon Vehicle Partnership and policy guidance from studies such as the Concawe/Eucar/JRC well-to-wheels study of different alternative fuels.

    —  UKPIA believes that the UK's energy policy should continue to be based on maintaining a reliable UK energy system meeting all three pillars of sustainability—economic, environmental and social—with clear targets underpinned by a framework for their achievement. Policy objectives should not be dominated by any one of these pillars and should also avoid "picking winners". Sound science should be a cornerstone of this policy to ensure goals are met cost effectively.

    —  The whole process of refining fuels and producing the range of quality fuels that the market requires is highly complex. The incorporation of biofuels into this mix will increase complexity and it should not be assumed that replacing petrol and diesel with biofuels will automatically improve security of supply. For example, after a bad harvest or if bioethanol supply to a distribution terminal is interrupted the supply of petrol to the region served by that terminal will also be interrupted. This is an extra risk that does not occur with 100% fossil fuels.

RESPONSES TO QUESTIONS POSED BY THE COMMITTEE

Q1  What are the possible positive and negative social, environmental and economic consequences of biofuels? How might trade-offs between climate benefits and environmental and social impacts be made? Is there a need to develop a new biofuel strategy for the UK or EU, to balance the environmental, social, economic and climate impacts of biofuels?

  1.  The positive aspects of biofuels include a reduction in greenhouse gas emissions from the road transport sector and support for the rural economy. The negative aspects include:

    —  Competition between road fuel and food potentially leading to higher food prices. There is may also be future competition between biomass for road fuels and power generation and between feedstock for some chemicals and road fuels.

    —  Biodiversity—reduction in numbers: extinction of species eg orang-utan.

    —  Effects of monoculture on local food production and local economies.

    —  Pollution and environmental damage (water / soil / air), including related socio-economic impacts.

    —  Placing stress on the world's limited water resources.

    —  Net greenhouse gas balances resulting from land use change Deforestation -the destruction of High Conservation Value Forest (HCVF).

    —  Land use change—eg destruction of rain forest in Indonesia for palm and in Brazil for soy: ploughing Cerrado in Brazil for sugar cane; planting on peat soils.

    —  Land rights, including economic and physical displacement.

  This is not an exhaustive list. The concerns are real but not new.

  2.  In examining EU policies driving the greater use of biofuels it is important that different national priorities are borne in mind. At national level, there are three main policy objectives behind the use of biofuels:

    —  supporting the agriculture sector;

    —  reducing EU dependence upon imported oil; and

    —  reducing greenhouse gas emissions from road transport.

  In the UK, the main policy objective of the Renewable Transport Fuel Obligation is reducing Greenhouse Gas emissions from road transport, whereas in most other EU counties the driver appears to be support for local agriculture.

  3.  Biofuels can lead to Greenhouse Gas (GHG) emission savings compared with fossil fuels. However, the level of saving is highly dependent upon the type of feedstock, the source, method of cultivation, processes employed, and primary energy inputs. Current biofuels can potentially offer around 50% lower GHG emissions on average than fossil fuels, with the exception of bioethanol from sugar cane, which could offer up to 89% greenhouse gas reduction. However, as mentioned, GHG emission savings for both bioethanol and biodiesel vary significantly depending on sources and production routes. Furthermore, the uncertainty of biofuels supply sources and in emissions from different biofuels, particularly as global demand grows, would result in considerable uncertainty in regard to the level of GHG emission reductions. Concerns over sustainability also revolve around the effects of intensification and expansion of agricultural activities associated with energy crops, land use changes and forest clearance.

  4.  For this reason, it is important to make comparisons of GHG emissions on like for like basis, often referred to as "well to wheels" for petroleum products and their substitutes ("field to wheels" calculation for energy crops). The most comprehensive EU "Well to Wheels" study (CONCAWE, EUCAR and JCR, 2005) concluded that biofuels such as biodiesel: "are critically dependent on manufacturing processes and the fate of by-products". The use of the by-product or waste stream is particularly relevant in the calculation of GHG saving, a good example being Brazilian ethanol from sugar cane where the waste material is used to produce heat for the distillation process. The study did not cover land use change but this has been addressed in the reporting for the RTFO.

  The table below set out likely reductions in Greenhouse Gas Emissions on a well to wheels basis for some of the products likely to be used to meet the RTFO:

Table 1

WELL TO WHEELS GREENHOUSE GAS EMISSIONS


Fuel
Wells to Wheels Greenhouse
Gas Emissions
g CO2 equivalent/km

Petrol
196
E5—95% petrol : 5% ethanol from sugar beet
193
E5— 95% petrol : 5% ethanol from sugar cane(Brazil)
188
Diesel
164
B5—95% diesel : 5% biodiesel from rape seed
160


  Source:  Concawe/JRC/Eucar 2005

  5.  Feedstock for biodiesel production such as palm oil and soy has been widely associated with major land use change and deforestation particularly in Latin America, Sub-Saharan Africa and in South East Asia (FAO Report, Livestock's Long Shadow: Environmental Issues and Options, 2006). Carbon stored in/on land is released when that land's use is changed from say forest to arable land or permanent grassland to arable land. However, estimates over the release of carbon stored vary. Nonetheless, it is widely accepted that emissions from certain land-use changes, particularly de-forestation, are far greater than from the savings made by the biofuels produced on the cleared land.

  6.  Second generation biofuels, ie from fermentation of pre-treated straw, gasification of wood followed by Fischer-Tropsch synthesis of diesel, etc, utilise a wider range of biomass material, give better quality fuels, offer advantages in terms of CO2 reduction and do not displace food crops. However, they are expensive and at an early stage of development (DEFRA Biomass Task Force Report 2005) with trial plants at the demonstration stage, for example the Choren wood gasification plus Shell Fischer Tropsch technology for producing jet/diesel or the Iogen production of ethanol from straw.

  7.  It is also important to address the potential social impacts of biofuel production. A number of negative potential consequences have been cited particularly in regard to developing countries. Amongst the social issues of great concern are forced labour and low wages, child labour, health and safety risks, as well as displacement of people and food products by energy crops. Equally, if properly managed with equitable benefits, the development of biofuels could present a new income stream for developing countries.

  8.  Most fuel and technology solutions have trade-offs in terms of relative environmental and economic impact and cost. In case of conventional biofuels, aside from variations in greenhouse gas savings associated with source material/processes, there are differing views about sustainability and impact upon food prices. In the case of the latter, it is reported that some of the recent price increase in corn, wheat, soy and palm oil is associated with increased demand for biofuels. However, the weather, growing demand and changing tastes in rapidly developing countries could be stronger factors as biofuel usage is still modest outside Brazil.

  The RTFO will include both greenhouse gas and sustainability reporting from April 2008. The oil industry supports the use of sustainable biofuels and through the Low Carbon Vehicle Partnership's Fuels Working Group, which has lead the development of a reporting system and the criteria needed for sustainable biofuels, including carbon emission from land use changes. Until this reporting is both proven and operable UKPIA does not support setting targets for biofuels in road transport beyond the current 5% level. This will enable the issues of sustainability and any impact on food prices to be fully addressed.

  The reporting system uses a meta-standard approach that builds on existing standards eg the Roundtable on Sustainable Palm Oil. UKPIA believes that this approach offers the best way forward. Along with the RSPO, RTRS (Roundtable on Responsible Soy) and BSI (Better Sugarcane Initiative), other new biofuel crops will have to be covered as well. It is also important to note the recent improvement of the Assured Combinable Crops Scheme (ACCS), which is widely used in the UK, which now covers all the sustainability indicators required by the Renewable Transport Fuel Obligation.

  The key to long-term biofuel use is Government action to introduce sustainable reporting within the EU to generate strong market pull that will encourage biofuel producing countries to develop standards such as the Better Sugar Cane Initiative.

  9.  The economic benefits of biofuel expansion again vary considerably. Within the EU, policy is applied within the framework of the Common Agriculture Policy and applicable WTO rules, so although there are benefits to the EU agricultural sector, the climatic and available land mass advantages of material sourced from overseas countries give some imports a competitive advantage eg Brazilian ethanol from sugar cane. For developing countries production of energy crops could present a valuable opportunity provided important issues of sustainability are addressed.

  10.  Another aspect concerns the generally higher cost of biofuels, which is passed on to the end consumer, and the variety of fiscal incentives—both for growing/production and duty rates— that many countries offer to producers. In the UK, with the advent of the RTFO, the emphasis is moving away from an incentive through a lower duty rate, to a buy-out penalty on the fuel supplier for failure to meet the requisite obligation on biofuel content.

Q2  Should biofuels be regulated to minimise the negative environmental and social impacts, and in what way? How might regulation fit in with international trade agreements and rules? Should there be regulation of the entire carbon cycle of biofuels?

  1.  As outlined in our response to Question 1 above, UKPIA supports the need for biofuels to meet environmental and social standards.

  2.  However, we believe there are a number of hurdles to be overcome before mandatory environmental standards can be implemented:

    —  any system would have to be equitable for existing biofuel producers/processes;

    —  a widely accepted set of criteria/indicators of environmental performance would need to be agreed by all producers, probably on a crop by crop basis;

    —  existing systems such as the Roundtable on Sustainable Palm Oil (RSPO), the Roundtable on Responsible Soy (RTRS) and the Better Sugarcane Initiative (BSI) need to be in operation along with an UK/EU system in place (eg the equivalent of the improved ACCS). This is potentially several years away, especially as the focus of BSI seems to have shifted from absolute performance to an improvement target;

    —  an EU-wide approach is required to drive the market; and

    —  targets have to be "crop neutral" to avoid a WTO challenge.

  Once the reporting systems have been proven to operate successfully, then the Government should push for the principle of sustainability of biofuels to be incorporated into EU biofuels legislation.

  3.  Likewise, greenhouse gas accreditation is an important aspect of the whole process for the reasons outlined above as greenhouse gases saved depends on the type and source of the material as well as the conversion processes involved. Again a proven, accurate, operable system needs to be available before mandatory requirements are put in place.

Q3  How successful are existing international structures, such as the Roundtable on Sustainable Palm Oil, at ensuring that imports of biofuels can be obtained from sustainable sources? To what extent is it currently possible to identify the provenance and production standards of imported biofuels?

  1.  The oil industry supports the use of sustainably sourced biofuels and through the LowCVP's Fuels Working Group has helped develop a reporting system and the criteria needed for sustainable biofuels, including carbon emission from land use changes. The reporting system used a meta-standard approach, which builds on existing standards eg the Roundtable on Sustainable Palm Oil. We believe that this approach offers the best way forward but the systems required are not yet in place for all crops.

  2.  The RTRS (Roundtable on Responsible Soy) and BSI (Better Sugarcane Initiative) are not developed yet so are of limited use in the RTFO's early years. The RSPO should be operable around the start of the RTFO. New biofuel crops will have to be covered as well.

  3.  At the moment much of the source material for biofuels is imported but also augmented in the case of biodiesel by re-processed used vegetable oil. With the rapid expansion in biofuel feedstock demand, the number of sources will increase, so for this reason it is important that the reporting criteria referred to above are put in place, as well as adherence to quality standards to avoid potential significant quality problems when biofuel is blended with conventional petrol and diesel. An important objective for the industry is to put in place robust systems to ensure that consumers discern no difference with the switch to biofuel blends.

Q4  At what stage is biofuel technology? Is there enough support for the development of biofuel technology? A UN report found that the climate change benefits of solid biomass fuels outweigh those of liquid biofuels. Are current policies promoting the development and deployment of a range of biofuel technologies? How successful have EU strategies and Directives been in stimulating biofuel usage? Will the 2010 biofuel target be reached? How effective are the Government's fiscal arrangements for biofuels?

  1.  A variety of fuel and vehicle technologies have the potential of delivering a significant reduction in greenhouse gas emissions. These need to be compared on a "wells to wheels" or "field to wheels" basis and the most cost effective options encouraged, whilst maintaining a level playing field. Biomass from short rotation coppicing or miscanthus used to generate power, gives the best CO2 saving—see table 1 below.

Table 1

CARBON DIOXIDE EMISSIONS ABATED BY THE USE OF CURRENT BIOFUELS


Crop
Carbon dioxide saved

Bio-ethanol from sugar beet for blending with petrol
3.8 te/ha
Bio-ethanol from wheat for blending with petrol
1.3 te/ha
Bio-diesel from rape seed for blending with diesel
2.0 te/ha
Biomass (SRC or miscanthus) used to raise power
16.0/te/ha


  Source:  Concawe/JRC/Eucar 2005

  2.  There are a number of emerging second generation biofuels based on non-food crop biomass. The production of synthetic diesel from wood (ie biomass to liquids or BtL), is currently at the process demonstration phase with the Choren "beta" plant in Germany. This plant will demonstrate the process and provide design information for the first commercial scale plant, which could be in operation by 2015. The major barriers to the widespread use of BtL technology include proving its viability in terms of technology, the high capital cost, and the need to establish the necessary large supply of sustainable biomass. (Cost information on BtL is available from the National Non-Food Crops Centre at Heslington, near York.) Ethanol from straw would have a slightly shorter timescale, but still needs to be commercially proven. On the other hand, the production of biogas (bio-methane) from waste etc. is established technology, widely used in the UK for power generation. However, the use of wood, waste etc, to generate electricity will, in most cases, give a greater reduction in greenhouse gases than if converted to road fuels.

  3.  In reducing GHG emission, the most effective uses of biomass should be encouraged, not just conversion to road fuels which is a less cost effective method of saving GHGs, For biomass this would mean extending its use from transport fuels to heat and power generation. In the UK, studies by a number of groups, including the DEFRA Biomass Task Force lead by Sir Ben Gill in 2005, have highlighted the higher potential and lower cost per tonne of carbon saved. This application may also be of greater benefit to security of energy supply than conversion of biomass to liquid road fuels. An example is Denmark, which in 2003, obtained over 11% of its energy from biomass: mostly straw, wood, agricultural waste, general waste and wood waste.

  4.  The oil industry is already undertaking or supporting research and development into a range of biofuel/biomass sources and processing technologies. These include `second generation' processes to produce ethanol from the fermentation of ligno-cellulose from straw or diesel from the gasification of wood followed by the use of the Fischer-Tropsch process. Indeed, second generation biofuels utilise a wider range of biomass material, give better quality fuels, offer advantages in terms of GHG reduction and do not displace food crops. However, as mentioned above, they are relatively expensive and the technologies are yet to be demonstrated on a commercial scale.

  5.  In addition to the processes above, current research also encompasses incorporation of biofuels into refining processes (hydrogenation of biodiesel or conversion of vegetable oils to biodiesel with bio-ethanol instead of methanol from fossil fuels), as well as examining the effects of different fuels and blends with engine and exhaust clean-up technologies.

  6.  As regards targets, UKPIA has advised the Dept. for Transport that the RTFO's biofuels 2010-11 target of 5.2632% of fossil fuel sales (=5% of total road fuel sales) is unlikely to be fully met. A margin of safety is required to ensure that the 5% limit on ethanol in petrol and FAME (biodiesel) in diesel set in the European Fuels Standards are not breached and vehicle warranties invalidated. High blend biofuels eg E85 or B30 are niche products and will not fill the gap, especially as their use will significantly increase the cost of fuel for the motorist. They would also require new national distribution systems, which would be expensive. This will result in companies paying the buy-out price for the small volume affected rather than introducing expensive high biofuels blends and in-turn motorists paying for carbon reductions that are not delivered. UKPIA believes that targets set should be stretching but achievable. UKPIA also believes that additional biofuels targets should not be set until the RTFO's sustainability reporting has been proven. This will result in a short delay in setting but not achieving the 2020 targets for 10% biofuels in petrol/diesel adopted by the EU's 2007 Spring Council.

  7.  Fiscal and regulatory policy can do a great deal to encourage early adoption of technology. Experience in the UK has indicated that consumers need to be incentivised via fiscal measures, to take up new fuels that are more costly than conventional petrol or diesel (eg leaded petrol, ultra low sulphur diesel, biofuels etc). However, it is important that "winners" are not chosen by favouring a particular technology with advantageous fiscal treatment. To date, most EU Member States have adopted the approach of duty reductions, or in some cases, exemption from duty, for biofuels in order to kick-start the market. In the UK, the fiscal stimulus (duty reduction of 20ppl introduced start of 2005 for ethanol and 2003 for biodiesel) has had the effect of boosting demand for biodiesel and bioethanol, prompting the construction of a number of new plants. This approach is not sustainable in the long-term in terms of cost to the taxpayer.

  8.  However, it should be noted that biofuel producers in the UK have expressed concern that an obligation and fiscal incentive may be required in the early stages of the RTFO to ensure that development of the sector is underpinned.

Q5  The EU Strategy for Biofuels claims that biofuels "are a direct substitute for fossil fuels in transport and can readily be integrated into fuel supply systems". What proportion of UK domestic transport and energy generation could be fuelled by UK-produced biofuels? Is it possible for biofuels to entirely replace oil for transport purposes? Is there a role for public procurement or public transport? Will biofuels improve fuel security? How secure are biofuel crops from unexpected events such as drought or disease?

  1.  An advantage of biofuels is that in the main they can be blended up to a low limit (currently 5%) with conventional petrol and diesel and distributed through the same systems. In the case of ethanol into petrol this will be done at road loading points to avoid the risk of moisture "pick up" being transferred to other fuels in multi-product pipelines.

  2.  Assuming that all the biofuel production planned is built and the product used domestically then all the biodiesel and bioethanol required to meet the 2010-11 RTFO target will be produced in the UK. However in practice some biofuel will inevitably be imported. In the longer term the UK could supply around 10% of its road fuel needs from first generation biofuels using current arable land and current exports of wheat. Second generation biofuels could extend this figure.

  3.  Furthermore, the International Energy Agency states that, whilst at present biofuels represent 1% of global transport fuel, they could account for 7% by 2030 (the limit of their forecast) but that the use of fossil fuel in global transport will still increase in absolute terms. This is in line with other forecasts, ie ExxonMobil's below:


  Post 2030, oil will continue to be a major source of transport fuels. For instance, the World Business Council for Sustainable Development's Report "Pathways to 2050" forecasts that fossil fuels will supply 60% or road transport fuels with hydrogen (25%) and biofuels (15%) making up the balance.

  The Markal model used for the 2007 Energy white Paper gives a range of results for different scenarios; for example:


  The average over a number of the Markal scenarios given below highlights there is still a significant role for petrol and diesel in 2050.

Average share of transport fuels in 2050 from Markal model over range scenarios


Fuel
Predicted Market Share

Petrol
20%
Ethanol
6%
Methanol
2%
Diesel
26%
FT Diesel
26%
Bio Diesel
5%
Hydrogen
11%
CNG
0%
Electricity
4%


  4.  It can be concluded, therefore, that over the next 25 years liquid fuels will continue to dominate the road transport market. As shown, these will be predominately fossil fuels (petrol and diesel) with limited penetration of biofuels. Gaseous fuels will play a limited role until hydrogen / fuel cells are ready for the mass market (estimated at 2030+). At the same time the development of alternative fuels eg synthetic (Fisher Tropsch) diesel from biomass, needs to continue. Indeed, a variety of fuel and vehicle technologies have the potential to deliver a large reduction in GHG emissions, in combination with improved vehicle fuel efficiency and changes in consumer behaviour with regard to vehicle purchasing decisions and use.

  5.  The European technical fuel standards body CEN is examining the feasibility of increasing the current 5% by volume limit of biofuel blended with conventional petrol and diesel, possibly to 10%. At the moment the main biofuel constraint appears to be on the supply side (crops and processing capacity) rather than technical standards.

  6.  As regards security of supply and reducing dependence upon imported fossil fuels, the European Commission's scenarios on sources of biofuels in 2020 (European Commission's Biofuels Progress Report staff Working Document SEC, 2006, 1721/1, 10 January 2007, Table 1) shows that even considering the lowest level of biofuels' usage, which would equal to 7% of energy in road fuels), imports will play a crucial part.

European Commission Scenario for Source of Biofuels—7% of road fuel energy case


  Source European Commission

  7.  Furthermore, as the EU, Japan and the USA etc. incorporate biofuels into their petrol and diesel, the demand for biofuels will soar. This could lead to physical shortages of sustainable biofuels, especially in case of a poor harvest. Setting future targets once the availability of sustainable biofuels is better known would be a prudent course to adopt.

  8.  Moreover, bioethanol for instance will certainly play a part in further reducing the UK demand for petrol (already 25% lower in volume terms vs.1990) which is already in surplus in the UK. The excess has to be exported to the USA, as the whole of Europe already produces excess petrol. However, if the US continues to pursue its own biofuels programme, then its market may not be open for UK exports. This in turn could lead to closure of a UK refinery with a subsequent reduction in security of supply for other transport fuels, such as jet fuel where the UK relies heavily on imports. In addition, the production of finished petrol at distribution terminals could also lead to temporary stock outs if fuel quality issues are encountered or in case of bioethanol supply issues.

  9.  When biofuels become an established part of the overall fuel mix, issues of their continuity of supply and quality will become additional significant factors in an already highly complex process of producing the fuels that consumers require in a timely fashion. Consequently, UKPIA feels that security of supply issues should not be overlooked or assumed that biofuels will necessarily improve security of supply.

Q6  What impact would an expansion of UK production of biofuels have on the ability of the UK to produce its own food? How might this impact on greenhouse gas emissions from international trade patterns? What impact might the expansion of biofuels have on international food security and prices?

  1.  It is estimated that meeting the current RTFO target for 2010-11 would create a UK biofuel requirement of approximately two million tonnes per year, requiring in the order of 1.3 million hectares of land given over to production of biofuel crops. This is well below the two million hectares of available arable land indicated in a 2002 report from DEFRA so would not affect food production, unless crops for power generation were also grown extensively. The amount of land required would be reduced if the 3 million tonnes of wheat currently exported was used to produce bioethanol. This indicates that domestic production of first generation biofuels could substitute around 10% of conventional petrol and diesel, provided only a limited area of land is used to grow crops for power/heat. However, better use of biomass, particularly waste material or by-products, in power production would lessen the impact on land available for food production.

  2.  UKPIA recommends a cautious approach to increasing the biofuel content of fuels beyond those currently required by the RTFO, in order to allow time for the reporting systems on carbon and sustainability to be fully developed and for the impacts on biofuel supply and prices to be assessed before a further major expansion is set in train.

  3.  Clearly there will be an effect upon prices of energy and food crops until demand and supply become more closely aligned. Although there may be "surplus" production of food crops any reduction in one country by alternative use leading to reduced exports, needs to be counterbalanced elsewhere if prices internationally are not to be affected. Furthermore, the increased linkage of the price of energy crops with those for conventional fuels, as a result of growing biofuel demand, will be an additional factor in pricing, aside from the direct pricing consequences of increased physical demand for crops for competing uses.

4 October 2007





 
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